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I just finished a post at Forbes.com about the proposed compliance defense (http://onforb.es/pOl18T). In it, I cite to the famous Schedule C that seems to be included in each DPA recently outlining what the Department believes an effective compliance program comprises. Just as I went through all of the UK Bribery Act Guidance Case Studies, I’m going to go through each and every one of the 12 elements the DOJ says are in an effective anti-corruption compliance program. Obviously, this is going to be an effort. I hope you find it useful. First up: Clearly worded policies. Look for it soon.